Recommendations for the 2018-2019 Department of the Treasury and Internal Revenue Service Priority Guidance Plan Related to the Act

AMERICAN BAR ASSOCIATION SECTION OF TAXATION May 24, 2018 The Honorable David Kautter Assistant Secretary (Tax Policy) Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC 20220 David Kautter Acting Commissioner Internal Revenue Service 1111 Constitution Avenue, NW Washington, DC 20024 William M. Paul Acting Chief Counsel Internal Revenue Service 1111 Constitution Avenue, NW Washington, DC 20224 Re: Recommendations for 2018-2019 Priority Guidance Plan Dear Messrs. Kautter and Paul: The American Bar Association Section of Taxation (the "Section") welcomes the opportunity to provide recommendations for inclusion in the 2018-2019 Priority Guidance Plan. [...]the Section intends to submit two sets of recommendations. Affiliated and Related Corporations Partnerships and LLCs Closely Held Business Real Estate Corporate Tax S Corporations Foreign Activities of U.S. Taxpayers Transfer Pricing Foreign Lawyers Forum U.S. Activities of Foreigners & Tax Treaties Although the members of the Section of Taxation who participated in preparing this list have clients who might be affected by the federal income tax principles addressed by these recommendations, no such member or the firm or organization to which such member belongs has been engaged by a client to make a government submission with respect to, or otherwise to influence the development or outcome of, the specific subject matter of these recommendations. [...]the remaining guidance recommendations address important issues, but generally affect future tax years.